United States
Environmental Protection
Agency
Office of Water
4301
EPA-820-R-95-007
    July 1995
Industrial Pollution
Prevention Project (IPS)
Summary Report

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NOTE TO READER:      The format of this summary report has been designed so that the
                          findings and conclusions of each IPS document or overall document
                          subject are contained in an exact even number of pages. This makes
                          it possible to copy pages and obtain a handy, precisely self-contained
                          summary of a particular document or overall document subject.

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                                SUMMARY REPORT

                                        of the

             INDUSTRIAL POLLUTION PREVENTION PROJECT (IP3)
As part of EPA's emphasis on pollution prevention, the Agency set aside 2% of its FY1991 and
FY1992 contract budgets for new pollution prevention initiatives. One of the proposed
initiatives selected for funding and initiated in 1991 was the Industrial Pollution Prevention
Project (IPS). The IPS was an Agency-wide, multi-media project undertaken to examine:

       O     how industrial pollution prevention can be incorporated into EPA's regulatory
             framework, and

       O     how the pollution prevention ethic can be promoted throughout industry, the
             public, and all levels of government.

Outputs

In addition to establishing the institutional framework for ongoing pollution prevention (P2)
implementation in four geographical regions, the IPS has produced the following 23 documents:

             P2 Barriers and Incentives Study
             Statute Analysis
             Analysis of EPA's Effluent Guidelines Process
             An Effluent Guidelines Retrospective  on the Leather Tanning Industry
             Studies of P2 Technologies for Selected Effluent Guidelines Industries
             IPS Focus Group Recommendations:  The Effluent Guidelines Process
             Waivers for Technology Innovation
             Proposed Clean Water Act Legislation
             International P2 Case Studies
             New England Demonstration Project
             New England Demonstration Project:  EPA Region 1 Report
             New England Demonstration Project:  Building Partnerships for P2
             Nebraska Demonstration Project
             Nebraska Demonstration Project: Technical Report #1
             Nebraska Demonstration Project: Technical Report #2
             Southern  California Demonstration Project
             Southern  California Demonstration Project: Technical Report
             Pacific Northwest Demonstration Project
             Pacific Northwest Demonstration Project:  Simpson Tacoma P2 Plan
             Pacific Northwest Demonstration Project:  Model P2 Plan (Pulp and Paper Mill)
             Pacific Northwest Demonstration Project:  Bibliography
             Consumer Education Handbook
             IPS Focus Group Recommendations:  P2 Information Sharing

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Participants

The IP3 was funded by six EPA Offices:

       Office of Water
       Office of Air and Radiation
       Office of Solid Waste
       Office of Prevention, Pesticides, and Toxic Substances
       Office of Policy, Planning, and Evaluation
       Office of the Administrator

       Some funds also were provided by the University of Nebraska (i.e., matching funds
       associated with an IPS grant to the university).
 EPA's Office of Water, which initially proposed the project, was designated the lead office. The
 Office of Water's Jim Lund, who developed the project, was designated the Director of the IPS.
 Project participants included all of those mentioned above, plus:

       Office of General Counsel
       Office of Enforcement
       Office of Research and Development
       EPA Region 1
       EPA Region 7
       EPA Region 9
       EPA Region 10
       Commonwealth of Massachusetts
       State of New Hampshire
       State of California
       State of Washington
       Local Government Commission in California
       Merrimack (River) Business Environmental Network
       Northeast Business Environmental Network
       POTWs in Massachusetts and in New Hampshire
       POTWs in California
       Several industrial laundries in California
       Simpson Tacoma Kraft Company in Tacoma, Washington
       Behlen Manufacturing Company in Columbus, Nebraska

 In addition, a 23-member IPS Focus Group of stakeholders - comprised of representatives from
 industry, labor, environmental groups, academia, and all levels of government (federal, state, and
 local) ~ was established through the National Advisory Council for Environmental Policy and
 Technology (NACEPT) and participated in all aspects of the project.

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              A SUMMARY OF MAJOR IP3 FINDINGS AND CONCLUSIONS

                           (from each of the 23 IPS documents)


1.     P2 Barriers and Incentives Study

(Industrial Pollution Prevention: Incentives and Disincentives  (EPA-820-R-94-004))

This study examines the most promising incentives to overcome existing barriers to industrial
pollution prevention.

It examines the regulatory, economic, technical/informational, and management/institutional
factors that affect whether an industrial facility decides to adopt or fails to adopt P2 measures and
suggests to policy makers appropriate incentives to overcome each of the barriers.

It also relates its findings and conclusions specifically to the metal finishing industry.

       Value

       Industries can learn from the information in the numerous case studies presented.
       Government policy makers and regulators can learn from the case studies and from the
       study's detailed discussions of its findings.

       Major Findings and Conclusions

       The study concluded that the four most important general motivators for P2 are:

             O     Economics — cost savings

             O     Technical and financial assistance — especially for small companies.

             O     Open communication — between the regulator and the regulated.

             And most important of all,

             O     Flexibility — especially regulatory. Can work best if multi-media.

       The study found, however, that the key "trigger" motivator for P2 is:

             O     A stringent regulation or an enforcement action.
       The study presents an overview of the P2 incentives and disincentives and suggests
       appropriate incentives to overcome each of the disincentives:  [see the matrices below]

                                           1

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Through numerous telephone interviews and site visits, the study also developed some
findings and conclusions related specifically to the metal finishing industry:

       O      Mass-based standards are motivators for P2. Regulators should be
              allowed the flexibility to use mass-based standards to achieve effluent
              goals.

       O      When enforcement and compliance activities are tied to a strong P2
              message, they can be a key motivator for facilities to adopt P2.

       O      Existing categorical standards do not provide an incentive for P2
              because they are outdated and are being increasingly superseded by non-
              technology based standards.

       O      Zero-discharge systems hold much promise for metal finishers seeking to
              maximize water efficiency and chemical recycling/reuse. But there are
              both regulatory  and technical/informational barriers.

       O      Economic factors have the potential to be an important incentive for P2.
              But there are often significant barriers — a fear of noncompliance, a lack of
              financial assistance, a general "status quo" inertia (e.g., wary of changes,
              preferring the security of proven profits under existing conditions) —
              countering this potential. Also, for small metal finishers, total cost
              accounting is usually not an effective tool for promoting P2.

       O      Flexibility in the regulatory network, supportive assistance/outreach, and
              collaborative relationships between industry, regulators, and the public
              can foster continuous, industry-wide improvement in P2.
 The study concludes by presenting:

       O     a detailed case example of the San Francisco Regional Water Quality
              Control Board in California, which illustrates the successful integration
              of P2 incentives to overcome barriers.

 The Appendices to the study include:

       O     14 case studies (nine from the site visits made during the study and five
              more taken from the Pollution Prevention Information Clearinghouse),
              which describe different companies, their situations, what specific P2
              measures they chose to undertake (or chose not to undertake), what
              influenced the decisions  they made, and the results.

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       Regulatory Factors in Pollution Prevention Decisions
 REGULATORY IMCENTIVES
PHffl If A
flexible, multi-media
regulatory framework
 single-media regulatory
 framework
specific toxics use
reduction laws or facility
planning statutes that
encourage firms to do P2
opportunity assessments and
audits
 single-media permits that
 focus on end-of-pipe
 Tffn-i -i romcn-t-a
compliance inspections
where NOVs are tied to a
pollution prevention
message  (e.g., referral to
state technical assistance
program)
 single-media inspections
 with no pollution
 prevention message (i.e.,
 quick-fix, end-of-pipe
 compliance focus)
flexibility within
compliance and enforcement
programs  (e.g.,extended
compliance schedules phased
to pollution prevention
activities, "soft landings"
for technical failure of
innovative technologies)
 inflexible approach to
 media-specific enforcement
 actions that allows no time
 for process innovation or
 exploration of pollution
 prevention solutions
strict local limits, with
POTW ordinance authority to
implement/enforce
 reliance on EPA categorical
 limits which may be
 outdated and set too low a
 compliance level
regulatory pressures on
POIffis such as EPA sludge
regulations, or air toxics
reduction requirements,
motivating POTWs to push
upstream sources to lower
metals in wastewaters—
ideally through pollution
prevention measures
 specific regulatory
 "barriers* such as RCRA
 Part B permit requirements
 for facilities implementing
 reuse/recovery technologies
 or "zero discharge" systems
SEPs with pollution
prevention requirements;
promotion of pollution
prevention alternatives in
enforcement case context
 guida
                   used by
permit writers that may be
outdated and focus on end-
of-pipe solutions
mass-based or total
loadings—based standards—
especially for water
intensive industries—that
may. encourage water
reclamation/recycling/re—
use
concentration-based
standards  that may
           water
reclamation/recycling/
use

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      Economic Factors in Pollution Prevention Decisions
  HOOMGMIC
ECONOMIC DISINCENTIVES
lower facility operational
costs that nay include:

— environmental management
cost savings  (e.g., from
eliminating RCRA sludges,
or decreased wastewater
treatment costs)

— production or process
cost savings due to lower
material or chemical use

— utility cost savings due
to lower water, sewer, and
energy usage

— lower liability costs
capital investment
requirement difficult or
impossible for many firms-

— firms may have limited
Or no Capital avajlabilifcy
due to low profit margins,
competing investment
priorities, or too much
environmental liability (a
"bad risk" for lenders)

— "sunken investments'' in
conventional pollution
control equipment

— many small firms--
especially "job shops"—
cannot tolerate down-time
for equipment upgrades or
process change/experiments
fee structures based on
pollutant loadings  (permit
fees, POTW fees, etc.) can
act as economic incentive
for pollution prevention
economies of scale for some
technologies may not be
realistic at smaller firms
(e.g., metal recovery
technologies, automatic
systems vs. batch)
R & D challenge grants,  low
interest loans, tax breaks
for equipment  upgrades,  and
other funding  assistance
mechanisms can be powerful
incentive—but only if
message gets to company
about availability  and if
application process is not
onerous
R & D costs for new
technologies and/or process
mm^-if ir!a<"jr>na may be
difficult to bear — also,
firm must be concerned with
          enforcement
related costs if technology
fails
enhanced product quality
and/or corporate image may
lead to higher revenues
customer dissatisfaction
with changed product may
mean loss of revenue
 full/total cost accounting
 methodologies can help
 firms identify economic
 savings and opporr-'mi *•-•?*»
 not readily apparent—but
 there is a real need for
 simpler, user-friendly,
 methods such as a; quick
 checklist or worksheet that
       fimm can USB
full/total cost accounting
to justify pollution
prevention expenditures can
be ttttplexr time-consuming,
and expensive (especially
for small firms)

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      Technical/Informational Factors in Pollution Prevention
                         Decisions
 TBCH/IKFO INCENTIVES
TBCH/INPO
technical assistance to
facility via state TAP or
POTW pretreatment programs
can overcome many
informational barriers
 facility unfamiliar with
 pollution prevention and
 potential for  in-process
 changes
targeted outreach to a
particular industry sector
via pollution prevention
workshops, seminars, or
training—provide forum for
industry to share success
stories and concerns
 facility uncertain of
 pollution prevention's
 ability to meet discharge
 limits; afraid to be first
 or to take risk
vendor lists or
certification programs to.
assure prospective
purchasers/service users
that vendor is both
reputable and knowledgeable
about pollution prevention
technologies
unscrupulous vendors who
misinform, misrepresent
and/or install inferior
equipment; so-called
"pollution prevention
experts" who sell a product
then disappear when the
system falls and the
facility falls out of
compliance
detailed knowledge of waste
generation and chemical
usage via facility audit/
opportunity assessment
 lack of detailed  knowledge
 of waste streams  and extent
 of in-process use of toxic
 chemicals
trade and industry
associations that encourage
and ^ "* ag**ni TVM"** pollution
prevention information
customer satisfaction
concerns—potential  impacts
of pollution prevention on
product quality,
appearance,, or performance
that could translate into
loss of customer  acceptance
permit writer and inspector
training on how pollution
prevention can achieve,
maintain, or even go beyond
compliance
chemical or product
substitution concerns: will
it: a) do the  job; b) be
consistently available;  c)
not become expensive; and
d) not trigger some other
unforeseen regulatory
nightmare
                                    proprietary information
                                    concerns—disincentive to
                                    sharing information,  data,
                                    and/or experiences with new
                                    processes

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           Management/Institutional Factors in Pollution
                   Prevention Decisions
             noamvES
           DISIMCEMTIVES
corporate policy supporting
pollution prevention or
incorporating it into
strategic planning
accountability within
management structure for
integrated (i.e., across
no upper management
ccmnitment to pollution
prevention
Oigppj'f^fnpnfcg _ OfOUDS • OH?
divisions) environmental
responsibility
lack of coordination and
accountability among
different groups in the
company (e.g., process
engineers/product design
engineers not talking to
environmental engineers)
willingness tc take risks
low tolerance for failure;
policy of risk avoidance
willingness to engage in
open dialogue with both
regulators and t^
assistance personnel
closed shop mentality;
afraid to ask questions—
"What I don't know won't
hurt me."
TQM programs that empower
employees to seek pollution
prevention opportunities
bean-counting disincentives
at regulatory agencies that
tie performance reviews to
number of enforcement
cases, number of permits,
etc. instead of rewarding
quality orwi mninorrt-al
results
potential for favorable
publicity; pollution
prevention helps present a
"good guy" image; like to
show progress (e.g., lower
TRI  na«b«r«)
do not want to
attention to themselves—
e.g., if company has been
"burned" once by EPA, will
be reluctant to try
anything now which might
draw more attention
      tiv« «nvir
within  (and between)
regulatory agencies;
openess to pollution
inertia: "If it ain't
broke, don't fix it."

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2.     Statute Analysis

( The Tools of Prevention   (An Environmental Law Institute Report done for the IP3) )

This analysis identifies and examines the industrial pollution prevention opportunities in two
major environmental statutes: The Clean Water Act (CWA) and the Resource Conservation and
Recovery Act (RCRA).

It seeks to discover the extent to which there is authority — within the existing legislation ~ to
move beyond controlling pollution to preventing it in the first plate.

       Value

       Government policy makers and regulators can learn, from this thorough analysis, about
       statutory authorities which currently exist in the provisions of the CWA and RCRA.

       Major Findings and Conclusions

       The analysis concludes:

              O      Existing statutes provide substantial (and still largely untapped)
                     authority to promote industrial pollution prevention using a variety of
                     regulatory methods.

              O      The existing statutes provide more than adequate authority to
                     promote industrial pollution prevention boldly, vigorously, and
                     without delay.

       The CWA and RCRA each provide opportunities to use already familiar tools to promote
       P2. The analysis presents four strategies already provided under current law:  direct
       regulatory action, standard setting,  incentives, and information management/outreach.

       With each strategy, the analysis identifies specific  opportunities for pollution prevention
       under the existing statutory authorities. Some examples of the opportunities identified by
       the analysis are the following:

       (NOTE: Statutory opportunities are not always easily translatable into implementation.)

              1.      Direct Regulatory Action

                           Banning the discharge of highly toxic pollutants.  (CWA)

                           Section 307(a)(2), though seldom invoked, nonetheless remains a
                           viable option for banning the discharge of toxic pollutants.

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             Putting conditions on NPDES permits that would directly
             promote pollution prevention.  (CWA)

             Requiring, for example, pollution prevention BMPs or a facility
             plan identifying P2 opportunities can be a condition of a permit.
             This could be done on a permit-by-permit basis or generically.

             Requiring waste reduction plans as a condition of receiving a
             treatment, storage, and disposal permit. (RCRA)

             A limitation is that this could apply only to generators required to
             obtain permits for on-site treatment, storage, and disposal — a
             subpopulation of all RCRA-regulated generators.

             Enhancing the Waste Minimization Program by doing more
             with generator certification and biennial reporting. (RCRA)

             Despite a tentative legislative history, the language of the statute
             provides the authority to require: (1) under generator certification,
             a description of the waste reduction program in place and why a
             more aggressive program is not economically practicable; and (2)
             under biennial reporting, development of a waste reduction plan
             and reports on results achieved.

             Imposing specific P2 measures as part of agency enforcement
             settlements  with violators.

             This can include not only P2 measures which correct the violation
             but also ones to be implemented additionally.
2.      Setting Standards
             Developing effluent guidelines that move industries toward
             preventing pollution. (CWA)

             Although the effluent guidelines are neutral with respect to
             whether an industry uses a particular technology or preventive
             method, EPA has the authority to promote P2 by using preventive
             methods as the basis for the guidelines.
                              8

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             Using water quality standards to promote prevention. (CWA)

             "the wasteload allocation process under Section 303 can be
             employed to leverage the use of P2 measures in chosen sectors.
             Also, under Section 304, toxicity reduction evaluations (TREs) can
             be used to identify P2 opportunities for reducing discharges.

             Using P2 technologies in setting BOAT standards.  (RCRA)

             Despite debate over the term "treatment" in Section 3004(m), the
             statute provides authority to develop prevention-based BDAT
             standards under the land disposal restrictions program.

3.      Incentives

             Charging a fee for pollution. (CWA)

             Some states already have fee systems — but primarily  to raise
             revenue, not induce P2.  Section 402 arguably provides the
             authority to institute an incentive-based fee system. But absence of
             clear congressional authorization  might be a problem.

             Allowing pollution trading. (CWA)

             Unlike incentive-based discharge fees, pollution trading has
             already been implemented by environmental regulators in the
             United States.  For several reasons, trading under the CWA may be
             appropriate only for conventional water pollutants.

             Extending compliance deadlines for innovative processes or
             technologies. (CWA)

             Section 301(k), intended to encourage innovation through
             compliance extensions, failed (see page 17 below).  A revised
             provision (see page 19 below) can be effective and promote P2.

             Extending compliance deadlines for newly-listed wastes.
             (RCRA)

             Statutory authority exists to give generators of newly-listed wastes
             a lengthened period of time to implement source reduction
             measures before the effective date of required waste management
             obligations. Enforcement penalties could possibly be  assessed
             against generators who use the extension improperly.

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                   Creating a P2 EPA procurement policy.

                   A precedent for using procurement incentives already exists under
                   RCRA, although it is designed to promote recycling rather than
                   prevention.  EPA could promote P2 more directly by revising its
                   own current procurement policy and establishing a P2 procurement
                   policy as an "additional" socioeconomic program under Part 26 of
                   the FAR.  Such a procurement policy could promote P2 by the
                   choice of products purchased. The FAR anticipates that agencies
                   will use their procurement policies to advance socioeconomic
                   programs of this nature.

      4.     Information Management and Outreach

                   Measuring progress in pollution prevention. (RCRA)

                   There are several ways (detailed in the analysis) that RCRA's
                   biennial reporting system can be used to measure P2 progress,
                   (including integration with the Toxics Release Inventory (TRI)).

                   Publicizing P2 performance. (CWA)

                   EPA has authority to identify firms that have risen above their
                   peers in implementing P2, and it can throw the spotlight on those
                   who continue to lag behind.  A P2 awards program could be
                   established, for example, under Section 501(e)(l) of the CWA.

                   Providing P2 technical assistance. (CWA+RCRA)

                   EPA can use its information-gathering authorities to gather P2
                   information and then share it (except that which is proprietary).

                   Establishing P2 as a top priority for grant-making.
                   (CWA+RCRA)

                   Section 104(a) of the CWA specifically authorizes P2 research.
                   Similarly, so does RCRA under subchapter VII. Under its general
                   authority, EPA can establish research priorities.

The analysis ends with these two sentences:

       "...There is a [statutory] basis to begin building a pollution prevention program
       based on solid regulatory action. The tools are clearly there."
                                   10

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3.     Analysis of EPA's Effluent Guidelines Process

( Consideration of P2 in EPA's Effluent Guideline Development Process  (EPA-820-R-95-008))

This analysis describes in detail the steps of the effluent guideline development process and
identifies where in the process pollution prevention can be considered.

       Value

       Government policy makers and regulators can learn and understand how the effluent
       guideline development process can and does incorporate P2 considerations.

       Major Findings and Conclusions

       The flowchart (next page) lays out the 18 steps of the effluent guideline development
       process and identifies those steps (the shaded boxes in the flowchart) where pollution
       prevention considerations and decisions can most appropriately be made.

       Also, a "snapshot" of effluent guideline P2 considerations, taken in 1995, is included in
       the analysis to show how EPA's effluent guidelines program is now  promoting P2 in
       the specific effluent guidelines (Metal Products and Machinery, Pesticide Formulating
       and Packaging, Pharmaceuticals, and Pulp and Paper) currently under development.

       The analysis ends with a listing of challenges and issues that remain to be resolved
       before P2 can be fully realized within the effluent guidelines process, such as:

             enabling the Effluent Guidelines Program to become more multi-media oriented

                    e.g.,   To what degree should EPA set effluent standards which result in
                           the most beneficial overall impact on the environment, accounting
                           for all media?  Should budgets for rule development be
                           administered by cross-media teams rather than by single-media
                           program offices? Should resources for rule development be
                           allocated specifically for multi-media analysis as a condition for
                           program funding?  Should  EPA have the authority in an effluent
                           guideline to prohibit use of technologies that have a significant
                           adverse effect on the environment through other media?

             finding a way to foster the flexibility that encourages P2 that can surpass BAT

                    e.g., see pages  15 through 22 below.

             achieving a P2 mindset in everyone, not only in standard-setting, but throughout
             the effluent guidelines process — including permitting, compliance, and
             enforcement.

                                          11

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                               Effluent Guidelines Flowchart
                             REGULATION DEVELOPMENT PROCESS
        Critical path

      Non-Critical path
 Industry Designated in
Effluent Guidelines Plan
                                      Review available data
                                      - identify data gaps
                                                                                id
SEPA
Effluent Guidelines Program
OVWOST/EAD 11/92
    Proposed
    Regulation
DeveJopnwnt Doeunwnl
Economic Impact Analysis
Environmental Assessment
                                             12

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4.     An Effluent Guidelines Retrospective on the Leather Tanning Industry

(Effluent Guidelines. Leather Tanning, and Pollution Prevention  (EPA-820-R-95-006))

This study was undertaken to learn:

       O     in what ways and for what reasons a specific industry in the past already was
             implementing P2 in order to comply with existing effluent guidelines; and

       O     to what degree the effluent guidelines development document for that industry
             had already previously projected that outcome.

       Value

       Government policy makers and regulators can learn from the past.

       Major Findings and Conclusions

       (NOTE: This study was intended to serve as a case study within the leather tanning
       industry and may not necessarily represent the leather tanning industry as a whole.)

       The study found that:

             O     The industry was already implementing pollution prevention in the
                    past to meet the effluent guideline requirements.

                                 Process changes and material substitutions were as
                                 important in meeting the effluent guideline requirements as
                                 end-of-pipe treatment.

             O     The effluent guideline requirements were the driving force behind the
                    implementation of pollution prevention — even if not the only reason.

                                 Adopted primarily to meet the guideline requirements, P2
                                 also brought improved product quality, process efficiency,
                                 and reduced water supply and treatment/disposal costs.

             O     The effluent guideline development document projections, while quite
                    accurate generally in the areas of end-of-pipe technologies, did not
                    forecast all the aspects of the pollution prevention creativity that was
                    exercised by the industry.

                                 Two major pollution prevention measures that were
                                 implemented by the industry were not referenced in the
                                 development document.

                                          13

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5.     Studies of P2 Technologies for Selected Effluent Guidelines Industries

( These were studies that were funded by the IPS and were an integral part of the current effluent
  guidelines' development.)

Some technical studies examined specific P2 technologies for effluent guidelines currently under
development.
       Government regulators and industry are able to learn about the technical characteristics
       and effectiveness of specific P2 technologies.

       Major Findings and Conclusions

       Major results of these particular studies included the following:

       O     For pesticide formulating/packaging facilities' operations, membrane filtration
              technology was examined through extensive on-site testing, as well as pilot
              bench-scale testing. It performed well; it provided a high recovery rate for certain
              active ingredients in the waste stream, thereby eliminating discharge of the
              pollutants and allowing for recirculation of process water. However, it proved not
              to be as flexible a technology as other alternatives. Also, in some applications the
              membrane has a tendency to become fouled, needing replacement - making it a
              relatively costly technology.  Therefore, it was decided not to cost it out as a basis
              for BAT in the proposed Pesticides Formulating, Packaging, and Repackaging
              Effluent Guideline.

        O     For electroplating and metal processing industries, a new process for recovering
              individual metals from plating baths and rinses was examined at a couple of
              facilities. This particular process uses oxalic acid as a precipitant.  The process
              was found to work well. However, it was found that, while some facilities can use
              it, others cannot.  Therefore, lacking industry-wide application, it was not used as
              a basis for effluent limitations in the proposed Metals Products and Machinery
              Effluent Guideline. However, recovery methods are discussed in the guideline's
              Development Document.
                                             14

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6.     IP3 Focus Group Recommendations: The Effluent Guidelines Process

( How Best to Promote P2 Through the Effluent Guidelines Process  (EPA-820-R-94-002))

The 23-member IPS Focus Group was a stakeholders group — comprised of representatives from
industry, labor, environmental groups, academia, and all levels of government (federal, state, and
local).

The Group, for 18 months, provided — for the IPS — a forum for constructive dialogue among all
groups affected by adoption of industrial pollution prevention. The Group developed specific
recommendations to EPA on "How Best to Promote Industrial Pollution Prevention Through the
Effluent Guidelines Process."

       Value

       Government policy makers, regulators, and the Congress can learn what the stakeholders
       themselves recommend, regarding P2 and the effluent guidelines process.

       Major Findings and Conclusions

       (NOTE: The Group considered the "effluent guidelines process" to include not only
       effluent guideline development (i.e., standard-setting) but also permitting, compliance,
       and enforcement.)

       To promote more industrial pollution prevention, the effluent guidelines process
       must (1) be more flexible, (2) address all media, and (3) impart a pollution
       prevention mindset to everyone throughout the effluent guidelines process.

       To accomplish this, EPA should adopt a specific new approach to the development
       and achievement of Best Available Technology (BAT) limits.

             1,      EPA should provide industry with an alternative approach that is more
                    flexible than the strict requirement to attain a single Best Available
                    Technology (BAT) effluent limit.

                    Industry should be permitted to achieve a level of effluent reduction
                    different from the single BAT limit — provided the facility will
                    implement pollution prevention measures that will substantially
                    reduce total emissions (all media considered) below an EPA-
                    established emissions reduction threshold.

                    The alternative approach must ~ in EPA's (and the State's or POTW's)
                    opinion -- be clearly a better environmental choice than simply meeting
                    the single BAT limit. Otherwise, the alternative approach must not be
                    granted.

                                         15

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      To encourage an industrial facility to choose the alternative approach and
      implement multi-media pollution prevention measures reducing total
      emissions (all media considered), EPA should offer ~ along with the
      alternative approach -- incentives on a case-by-case basis depending on the
      situation. However, no incentive should be offered that would increase
      harm to human health or the environment.

2.    EPA should offer incentives to industry to implement pollution
      prevention measures that reduce pollution beyond the traditional
      single BAT limit. (The Group's report suggests some possible incentives,
      including technical assistance (for implementing P2), extended permit
      length, extended compliance schedules, "soft landings," forgiveness of
      "brief excursions, awards, etc.)

3.    To further the incorporation of P2 into the existing effluent guidelines
      development process, EPA should:

             Encourage P2 actively in all parts of all the Agency's programs.
             Make the development of every effluent guideline multi-media.
             Conduct more dialogue with industry during the process
             modification/treatability studies and site reports.
             Continue to explore P2 technology used overseas.
             Use the P2 Information Clearinghouse (PPIC) in conjunction with
             the effluent guideline Development Document.
             ETC. (There are six more recommendations like these.)

       In addition, to get industries to do more P2, EPA should:

             Look for and find ways to develop and promulgate effluent
             guidelines more quickly in order to cover more industries.
             Make sure that enforcement personnel and policies promote P2.
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7.     Waivers for Technology Innovation

(Providing Waivers From NPDES Permit Compliance Schedules For Industrial Pollution
  Prevention Technology  (EPA-820-R-94-003))

This study examines the innovative technology waiver provision of the Clean Water Act. (The
provision is Section 301(k) and Section 307(e) for direct and indirect dischargers, respectively.)
Section 301(k)/307(e) — hereinafter referred to simply as 301(k) ~ provided an opportunity for
permittees to request that the date for compliance be extended for up to three years (later changed
to two years) if they use innovative technology to meet or exceed permit limits.

P2 often is, or can be considered, innovative technology. So studying past experiences with
technology innovation provisions like 301(k) can be important to understanding the potential role
of such a provision and how to change it to enable it to be effective in promoting P2.

The study examines why the past 301(k) program did not work. It presents a detailed and
thorough legislative and regulatory history of the program.

It also includes a comparison to the variance program under the Clean Air Act and highlights
several successful programs at the national and state levels that have promoted innovative
technology.

The study concludes with some suggestions for a redesigned 301(k)-type program to promote
innovative technology and P2. (See the following section 8. on Proposed Clean Water Act
Legislation for a proposed revision of Section 301(k) for a reauthorized CWA.)
       Government policy makers and the Congress can learn why 301(k) did not work and how
       it can be changed to be successful.  This understanding is especially important in the
       context of the current CWA reauthorization process.

       Major Findings and Conclusions

       The study found:

             O     In the fourteen years from the creation of 301 (k) in 1977 until its
                    expiration in 1991, it was hardly ever used.  On the basis of available EPA
                    records, there may have been as few as five 301(k) variance applications,
                    and only one variance approval (which had mixed results).

             O     Some of the reasons 301 (k) was not attractive and did not work were:

                           Regulatory uncertainty and conflict (e.g., 14 years of suits,
                           argument, and delay over regulations that never became final.)

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             The 3-year (initially) extension offered was not enough time.

             Uncertainty and high cost of the application process (e.g.,
             EPA's lack of enthusiasm for the process and the unwanted (and
             usually adverse) attention an exceptions process always brings.)

             Lack of a "soft landing"  (even for good-faith efforts)

O     Overall, the risks of the process seemed to most companies to exceed the
       benefits of the waiver.

O     For EPA, the perceived problems were resources, the likelihood of
       ingenuine applications, and the intensive nature of the exceptions process.

O     Even though partial remedies for some of the past problems of a 3 01 (k)
       process might include increased resources for permit writers, defined
       progress steps for recipients of waivers, and some form of "soft landing"
       mechanism, extension of the 301(k) process in its current form is
       unlikely to be more successful in the future than it has been in the
       past. Its fundamental flaw is that it requires relatively large resources to
       make individual case decisions within an exceptions process that makes
       each such decision highly visible, making all parties feel at risk.

O     An alternative might be to establish criteria within the effluent guidelines
       process for additional environmental goals which would need to be
       included in any permit providing alternative compliance deadlines for
       implementation of innovative technology.  Such criteria could include
       additional reductions in pollutant levels beyond the requirements in the
       guideline, or defined additional multi-media reductions.

O     While decisions on parameters for such tradeoffs might be difficult to
       make, they would occur up front in a context of overall decisions affecting
       all facilities covered by a guideline. The application process could then
       become a more standardized process, with less risk and requiring fewer
       resources. Furthermore, placing priority on environmental success rather
       than individual technical judgments would remove many of the
       troublesome issues that plagued 301(k).

O     The result would be a standardized process combining greater regulatory
       flexibility with pre-established parameters for compliance extension
       tradeoffs. 'By placing priority  on environmental success rather than
       technological judgments, such an up-front approach to the parameters
       could provide a more predictable and congenial atmosphere for the
       implementation of technology innovation and prove to be a more workable
       approach than the 301(k) program of the past.

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8.     Proposed Clean Water Act Legislation

Aware of the IPS study on waivers for technology innovation (presented above in the preceding
section), Congressional staff requested technical assistance from EPA on revising Section
301(k)/307(e) in the CWA reauthorization process.  This proposed legislation ~ rewriting
Sections 301(k) and 307(e) ~ was written by the IP3, approved by EPA, and provided in 1994 to
Congressional staff in both the House and the Senate upon their request.

It is based upon the Waivers for Technology Innovation study (presented immediately above),
the IP3 Focus Group Recommendations (see page 15 above), and work done by the Effluent
Guidelines Task Force which further developed the IP3 Focus Group Recommendations.
       It can serve as an improved Section 301(k)/307(e), resulting in a more effective CWA and
       increased implementation of innovative technology and P2. With the CWA undergoing
       reauthorization, this proposed legislation has been especially timely.

       The Rationale Underlying the Proposed Legislation

       O     Pollution prevention and technology innovation should be promoted in the
             reauthorized Clean Water Act.

       O     A simple way to do this is through a technology innovation provision — but
             not one like the old  301(k) provision. The old 301(k) provision did not work, and
             another one like it will still not work (see discussion on preceding page).

       O     Three basic changes need to be made to the old 301(k) provision to make it
             work and successfully promote pollution prevention and technology innovation.

                    1)     Industry must be  given sufficient time to enable the innovation to
                           succeed (e.g., up to three years from the date for compliance
                           (which would be  up to six years from effluent standards
                           promulgation)).

                    2)     If industry gets that much time, the provision must require
                           enhanced environmental results (i.e., either better results in
                           water or the same results in water with better results in other
                           media).

                    3)     The tradeoff parameters need to be predefined up front (e.g., hi
                           some regulatory document) but still provide for regulatory
                           flexibility (e.g., options for industry, such as the option referred to
                           in the parentheses in 2) above).
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O      The provision will work, only if it has the support of all the stakeholders. With
       the above three basic changes, all of the stakeholders get what they need to
       make the provision work.

              1)     Industry gets time and flexibility.

              2)     Environmental groups get enhanced environmental results.

              3)     Regulators get a more normal, standardized process putting less
                    strain on resources.

O     Although not as basic as the above three changes, two additional concerns
       should also be addressed in the new technology innovation provision.

              1)     There should be requirements that will ensure that industry will do
                    its very best to assure permanent attainment of the enhanced
                    environmental results.

              2)     There should be provided certainty of reduced noncompliance
                    penalties if a good-faith effort unexpectedly fails.

Some of the Important Finer Points Within the Proposed Legislation

O     The provision provides for a permit modification rather than a "waiver" for
       a couple of reasons. First, procedures already exist for permit modifications,
       whereas new procedures would have to be established for waivers.  Second, in
       reality the limits are not actually being waived but modified. So "modification" is
       a more accurate term to use in this context.

O     While the provision includes control technology and recycling as well  as pollution
       prevention, the Industrial Pollution Prevention Project (IP3) study of this subject
       area found  that industry is more likely to use a provision like this for pollution
       prevention  measures than for control technologies.  Therefore, the primary effect
       of the provision will probably be to promote innovative pollution prevention.

O     Although the term  "innovative" is not defined (that should be left to the
       regulations), the sense of the provision implies a relatively broad definition of
       "innovative." For example, there is no requirement that the innovative process
       or technology has to be previously undemonstrated. Further, there is no
       requirement that the process or technology has to have industry-wide application.
       Criteria like these are problematical in interpretation and therefore do not fit a
       provision that seeks to be simple and effective. If the objective is truly to foster
       pollution prevention, the provision has to be conducive ~ not problematical or
       restrictive.
                                    20

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O     The provision applies to both new sources and existing sources and to
       industries both with and without effluent guidelines.

O     Only for enhanced environmental results is a modification granted. For
       example, the modification is not granted for simply lower-cost technology.  The
       technology must produce enhanced environmental results.

O     Only an industry that is within the time period not exceeding three years
       beyond its compliance date can use this provision.

O     The maximum period of the modification (i.e., three years from the date for
       compliance) is actually six years from promulgation of the standards.

O     EPA is given the authority to establish predefined reduction parameters, as
       conditions to the modifications, but is not required to do so.  Therefore, EPA
       has flexibility  to decide how many of the reduction conditions to establish and
       even has the flexibility not to establish any of them, if it so chooses.

O     Establishing the predefined reduction parameters should not be a resource-
       intensive task. If done, it will probably be done in a regulatory document
       other than the effluent guidelines.

O     AH water quality standards of receiving waters are always  met — no matter
       what. Industry is never allowed to violate them. (Similarly, conditions in a
       POTW's permit are never allowed to be violated by indirect dischargers under this
       provision.)

O     The interim limitations are not burdensome ones that would require an
       industry to do  something extra.  They are either the water  quality-based
       limitations which the source must meet in any  case or previously effective
       technology-based limits which — if there were  such limits for that industry — the
       source is already meeting.

O     The period of the modification can vary by facility, depending on the situation;
       the predefined reduction parameters can vary by industry.
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      O     Because enforcing against the enhanced environmental results at the end of the
             period of the modification could be a strong disincentive for this provision, only
             the originally applicable standards will be enforceable at the end of the
             period of the modification. But the provision requires strict monitoring of
             progress during the period of the modification with the intent that permanent
             attainment of the enhanced environmental results, going beyond the
             enforceable standards, will be assured. Regulations for this provision could
             require (as part of the permit) a timeline of steps to be taken to demonstrate
             adequate progress.  A deviation from that schedule of progress would result in
             termination of the modification.

      O     The source will always eventually meet or do better than all applicable
             standards, while still preserving the other gains.

      O     The good-faith effort reduction in penalties can vary with the capital cost loss
             sustained by the facility, or other factors.
       The "Bottom-Line" Benefits of the Proposed Legislation

       O     The use of pollution prevention and innovative technologies will increase
             significantly.

       O     There will be greater protection of the environment over time.

       O     The normal rulemaking process for effluent limitations may be shortened
             because, with the regulatory flexibility offered by this provision, there may well
             be less litigation from industry and environmental groups over the issued
             limitations, This would enable more effluent guidelines to be promulgated
             quicker, resulting in cost savings to all the litigants and greater environmental
             protection.
NOTE:       While it would be desirable to have a reauthorized Clean Water Act containing
              this proposed provision, the key concepts embodied in this proposed provision are
              probably still implementable even if there is no reauthorized Act or no statutory
              change.
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9.     International P2 Case Studies

(International (Non-U.S.) Industrial Pollution Prevention (EPA-820-R-94-005) )

This compendium of over 200 case studies describes various pollution prevention technologies
that have been developed and used by industries in different countries around the world. The
case studies come from over 20 countries outside the United States.

The IP3 task which produced this compendium had four parts:

             gather all available information on P2 measures implemented by industries in
             other countries, which had not been previously gathered;

             put all this information into the form of case studies;

             compile all the case studies into a hard-copy compendium; and

             put all the case studies into electronic files so that they are accessible to all
             interested parties.

This is the hard-copy compendium.  It was prepared by the IP3 to provide interested parties with
easy access to non-U.S. pollution prevention case studies.

       Value

       EPA, U.S. industries, and industries around the world can learn from what industries in
       other countries are doing. This compendium can be helpful to plant designers, managers,
       and regulators around the world who are searching for creative ways to accomplish
       further pollution prevention.

       Major Findings and Conclusions

       The compendium includes many countries' experiences related to a variety of pollution
       prevention concepts and technologies.

       Before being included, all of the international case studies were reviewed to ensure
       conformity with U.S. EPA's concept of pollution prevention, i.e., the multi-media
       approach to protecting the environment that involves the use of processes, practices, or
       products that reduce or eliminate the generation of pollutants — before recycling,
       treatment, or disposal. (For this compendium, only source reduction or "closed-loop"
       recycling was considered to be pollution prevention.)  Over 200 passed that test and were
       included in this compendium.

       The information for the case studies came from a variety of sources:  United Nations
       Environment Programme (UNEP), Organization for Economic Cooperation and

                                          23

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Development (OECD), embassies and government environmental offices, proceedings
from various international conferences, trade journals, and assorted contacts abroad.

All information obtained was reviewed to ensure that case studies included in this
compendium (and added to electronic files) would be of interest and would provide
sufficient detail to be useful to intended audiences. In some cases, materials had to be
translated into English before being included.

Typically, each case study summarizes:

             the technology used
             its application
             the status of the technology's development
             commercial availability
             investment and operating costs
             cost savings
             payback periods
             feedstocks utilized
             wastes produced
             pollution reductions achieved
             regulatory issues
             any startup or implementation problems encountered
             contact name, address, and telephone number

The over 200 case studies are organized by industrial category in the compendium. There
are 20 industrial categories, such as electroplating, chemical manufacturing, pulp and
paper, petroleum refining, textiles, etc.

While most of the case studies demonstrate success stories, examples of failed efforts
(and the reasons for their failure) have also been included, because there is something to
be learned from failure as well as successes.

As indicated above, the case studies compiled for this hard-copy compendium were also
put into the electronic files of the Pollution Prevention Information Clearinghouse (PPIC)
and into the International Cleaner Production Information Clearinghouse (ICPIC) so that
they will be available electronically to all interested parties. Appendix A of the
compendium provides a reference guide to both the PPIC and the ICPIC.

Finally, the compendium includes a very helpful keyword index. The index lists the
keywords included in the case study abstracts with citations indicating the pages on
which each keyword  appears.

[NOTE: Subsequent to EPA publication in 1994 of this hard-copy compendium, the
United Nations Environment Programme (UNEP) in 1995 put this IPS compendium
on computer diskette for distribution around the world!]

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10.    New England Demonstration Project

(The Merrimack Project  (EPA-820-R-95-004) )  [a joint report written by MA and NH]

The IPS conducted Demonstration Projects in four different geographical regions across the
nation. The purpose of these regional pilot projects was to:

              demonstrate different specific aspects of the pollution prevention approach;

              gain new insights from the demonstrations that will be useful to both industry and
              EPA in furthering pollution prevention;

              actually prevent pollution at real-world locations; and

              initiate and establish ongoing pollution prevention activity and institutions that
              will continue on their own long after the IPS demonstration is over.

One of the four IPS Demonstration Projects was in New England. Named the "Merrimack
Project," it sought to demonstrate how two states (Massachusetts and New Hampshire) can work
together to bring about pollution prevention in the industries along a commonly-shared river (the
Merrimack River).

       Value

       Federal and state policy makers can learn from the experiences of these two states as they
       conducted this joint venture. The experiences are especially full of insights because the
       two states were so different institutionally.

       Industry can learn from the industry case study examples developed in this demonstration
       and from seeing how a regional "self-help" network of businesses became established to
       promote P2 within its sphere of influence.

       Major Findings and Conclusions

       The Merrimack Project demonstrated:

       O      Two states, even  when very different institutionally, can successfully work
              together to bring about P2 in the industries along a commonly-shared river.

                    The two states jointly exchanged frequent visits to one another's state
                    offices to share  ideas/information, learn from one another's experiences,
                    plan together, and build personal relationships among the staff.

                    The two states jointly conducted a series of industry-specific P2
                    workshops for Merrimack River industries.

                                          25

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             The two states jointly held two major P2 conferences:  an outdoor (under a
             tent) conference on a bluff overlooking the Merrimack River and another
             conference in Lowell, a city on the Merrimack River.

             The two states jointly performed P2 technical assistance during a number
             of industrial site visits.

             The following is quoted from the conclusions (page 64) of the joint report
             that the two states wrote on the Merrimack Project:

                "  This project has been essential in helping the New Hampshire
                   Department of Environmental Services jumpstart the process
                   of institutionalizing pollution prevention. Through this project
                   the department has been able to experiment with different
                   approaches and frame the questions which need to be addressed.
                   The project has also provided a forum to identify opportunities and
                   barriers in implementing pollution prevention in a regulatory
                   agency.

                   Working collaboratively with staff from the MA Office of
                   Technical Assistance has been a very satisfying and rewarding
                   experience. This project has proven that agencies from two
                   states can work together to accomplish common goals and
                   objectives, even though their program structures and
                   regulatory status may be different. Likewise, working with EPA
                   staff on the Merrimack Project has been very beneficial. EPA staff
                   provided flexibility as well as guidance, both of which were greatly
                   appreciated. Establishing new relationships and forming
                   innovative partnerships is what this  project was all about. It
                   seems almost certain that the relationships that have been
                   established will continue well beyond the life of the Merrimack
                   Project...."

The Merrimack Project achieved:

O     Greatly increased P2 implementation in the Merrimack River watershed.

             As many as 91% of the companies that were provided P2 information
             during the Merrimack Project actually implemented P2.

O     Measurement of actual P2 results brought by the Project.

             Sixty-two companies in the Merrimack watershed were visited with P2
             technical assistance by Merrimack Project staff during the project.
             (Almost 40 pages of the states' joint report on the project are devoted to

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             describing in detail these site visits and what was accomplished.) Data on
             actual P2 results were gathered concerning 49 of the companies, (These
             data are detailed in the states' joint report.)

O      Environmental improvement to the Merrimaek River and cost savings to
       Merrimack River industries.

             As a result of the Merrimack Project, already over 1.7 million pounds of
             toxic substances have been eliminated — with a savings of over SI.9
             million to industry. (NOTE: As detailed in the states' joint report on the
             Merrimack Project, these figures are based on reported data that were
             tabulated very conservatively, e.g., "thousands" = 1,000.)

             Some companies achieved P2 but did not produce data on money saved or
             pounds eliminated. These companies included:

                    A machine shop that ceased wastewater discharges with vacuum
                    distillation.

                    A manufacturer that reduced water use 87% and drummed waste
                    40%.

                    A semiconductor company with a closed-loop process.

                    Four electronic components manufacturers that eliminated TCA.

                    Two facilities that eliminated nuisance odors.

             In addition, several companies, while not reporting pounds eliminated or
             dollars saved, did improve compliance, e.g., by establishing proper
             hazardous waste storage practices.

O      Widespread interstate promotion of P2.

             The project conducted over 20 major workshops and over 100 public
             events promoting P2.

             (This was in addition to the over 200 on-site assessments of P2
             opportunities conducted by the project at over 60 industrial facilities
             throughout the Merrimack River watershed.)
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O      Establishment of new and lasting institutional commitments to P2.

              New Hampshire

                     As a result of the Merrimack Project, the State of New Hampshire
                     established a technical assistance program known as New
                     Hampshire's Pollution Prevention Program (NHPPP).  Prior to the
                     Merrimack Project, the State of New Hampshire did not have any
                     formal technical assistance program providing or promoting toxics
                     use reduction or pollution prevention.

                     The following is quoted from the states' joint report on the
                     Merrimack Project:

                        "   It must be recognized that at the beginning of the project
                           NH staff had a difficult time convincing companies that it
                           was safe to consult with them	The fact that NH's
                           technical assistance personnel convinced  14 companies to
                           let them come on site was therefore a substantial
                           accomplishment. NH's follow up resulted in a vast
                           majority of companies that worked with NHPPP stating
                           that they were very pleased with the service given to them
                           and that they would not hesitate to call on the program
                           again or recommend the program to other businesses."

                     The following is quoted from EPA Region 1 (New England)'s.
                     report (see 11. on page 32 below) on the Merrimack Project:

                          " As the Merrimack Project gained popularity, the NHPPP
                           was increasingly being asked to perform on-site
                           assessments, organize workshops, train staff, and respond
                           to informational requests....Within two years, NHPPP had
                           become recognized throughout New England as an
                           organization possessing the ability to identify and
                           characterize pollution prevention opportunities."

                     The following also exemplifies the extent of NH's commitment:

                        -   NH held a Solvents Bazaar, at which 55 companies had the
                           opportunity to bring parts needing to be cleaned to be
                           cleaned by alternative products.

                        -   NH held a P2 conference  in 1993, attended by 45
                           Merrimack Valley companies.
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          -   NH held a P2 conference in 1994, attended by 58
             Merrimack Valley companies.

          -   NH successfully established a P2 clearinghouse of
             information on new and innovative technologies, products
             and vendors, fact sheets, and case studies and made it
             available to businesses and industries. It has also
             successfully developed and instituted procedures for setting
             request priorities and disseminating information.

The Merrimack Business Environmental Network (MBEN)

      As part of the Merrimack Project, MBEN was formed. It is an
      ongoing forum of businesses committed to P2, to environmental
      compliance, to interacting with government agencies, and to
      mutual self-help. MBEN conducted monthly meetings for its
      members, at most of which there have been presentations or
      discussions of environmental requirements and P2.  (One of the
      purposes of the organization was to change the focus of the
      delivery of P2 information and the P2 message, so that it would
      come from business, not just government.)

      MBEN, with MA and NH, sponsored two major regional
      conferences, each of which garnered attendance of about 100.
      There were about 30 committed, active members of MBEN from
      the business community who came regularly to all MBEN
      meetings, with more than 80 registered as members, who came
      principally to  MBEN conferences. All  members pay dues and sign
      the MBEN mission statement, which reads as follows:

      "The Merrimack Business Environmental Network is a coalition of
      businesses, agencies and associations which is committed to a
      shared concern for the Merrimack Valley, its rivers, and the
      Valley's quality of life. This Association has made a long-term
      commitment to seek and implement solutions to promote pollution
      prevention through improved management and technology, while
      enhancing the economic viability of the business community."

      MBEN generated a good deal of interest in other regions, who
      sent in requests for information on how to create similar
      organizations.  To enable the network to reach a larger
      audience, MBEN became incorporated as the Northeast
      Business Environmental Network (NBEN) in September 1994.
                     29

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                   A focus of NBEN in 1995 has been on providing opportunities for
                   business and government to work together on regulatory
                   improvement.  Bylaws for NBEN stress the nonpartisan nature of
                   the group and prohibit it from engaging in political lobbying. The
                   most recent NBEN conference was in May 1995, and engaged the
                   attentions of the highest government officials in New England.
                   (Details of the May conference are included in the Appendices to
                   the states' joint report on the Merrimack Project.)

                   The enthusiastic participation of businesses in MBEN, now
                   NBEN, accomplishes one of the Merrimack Project's basic
                   purposes: to form a continuing, collaborative, working
                   commitment to P2 by all the stakeholders.

                   All the publicity that MBEN  received from the media resulted in
                   numerous newspaper and magazine articles including one in
                   Pollution Prevention Review (a copy of which is included in the
                   Appendices to The Merrimack Project report.)

Based on insights gained from the Merrimack Project, the two states' joint report on the
Merrimack Project concludes with 21 policy recommendations, such as:

O      U.S. EPA should re-evaluate regulatory program measures of success. Focus
       should be placed on actual pollution reductions and increases in compliance rather
       than number of inspections performed or enforcement actions taken.

O      More use should be made of the established POTW-industry relationship to
       promote P2. Often a POTW Pretreatment Coordinator already has an established
       working relationship with the industries he/she regulates. This relationship
       provides an excellent opportunity to further  the goals of P2.

O      U.S. EPA should encourage and support new and innovative partnerships.
       Through the Merrimack Project some new and unique partnerships were formed
       between state and private entities:  The Merrimack Business Environmental
       Network (MBEN) and the NHDES Merrimack River biomonitoring project are
       two examples.  Partnerships like these are a  very effective way to maximize
       resources while promoting pollution prevention.

O      Geographic initiatives especially should be encouraged and supported.
       Pollution and natural resources do not respect political boundaries: Watershed-
       based projects such as the Merrimack Project and the Merrimack River Initiative
       provide an ideal opportunity to transcend political boundaries and rally around a
       common environmental cause.
                                   30

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O      U.S EPA should review categorical discharge limits—and reset them
       according to what known P2 technologies and practices can economically
       achieve. Rachet limits down when technologically and economically feasible,
       according to frequent reviews.... The pressure of regulation drives companies
       toward P2. A certain sector does P2 because they are well informed and
       understand its value.  A larger sector does P2 because they have to.

O      Enforcement activities should require or encourage P2 and P2 reporting.
       Compliance orders should never simply order control technologies, but should do
       one of two things instead: either require P2 investigations or provide optional
       methods for coming into compliance.

O      Regulatory agencies should reorganize to the extent that functional activities
       can be coordinated with the goal of avoiding cross-media transfers — in
       permitting, inspections, enforcement, and in all policy formation and
       statements.

O      Water quality and discharge data should be made as accessible as TRI data
       are.

O      The formation of self-help groups of POTW personnel should be encouraged.
       Merrimack Project staff were impressed by the formation of the Massachusetts
       Pretreatment Forum, a discussion forum of and for POTWs in Massachusetts. It
       served a very useful function in keeping POTW officials up to date on P2 in the
       Merrimack Project. This group should be regarded as a model for encouraging
       the establishment of similar groups in other parts of the nation.
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11.    New England Demonstration Project: EPA Region 1 Report

( The Merrimack Project: A Report Bv EPA Region 1 fNew England^  (EPA-820-R-95-005))

[See the introduction under 10. on page 25.]

This EPA Region 1 (New England) report presents Merrimack Project results, implications, and
follow-on next steps ~ as seen from EPA Region  1 (New England)'s perspective.

       Value

       Government policy makers can learn from knowing how EPA's regional office views the
       results, implications, and follow-on next steps of the Merrimack Project.

       Major Findings and Conclusions

       The report presents the following results of the Merrimack Project:

              O    As an interstate effort, the project tested and demonstrated that two states,
                    even with technical assistance programs that are very different
                    institutionally, can successfully work together to provide technical
                    assistance to industries along a commonly shared river.

              O    The Merrimack Project also demonstrated that a technical assistance
                    program can be successfully structured and implemented under either a
                    regulatory or non-regulatory organization.

              O    The Merrimack Project demonstrated the value of publicizing the potential
                    for pollution prevention opportunities.

              O    The Merrimack Project achieved both cost savings to industry and
                    environmental improvement to the Merrimack River.

              O    Positive experiences with the project's workshops, technical assistance,
                    kept-confidences ~ combined with a desire to continue an intensified
                     ongoing level of communication on an industry-wide basis ~ led involved
                     Merrimack industries to work with the two states to form a Merrimack
                     Business Environmental Network (MBEN).  In turn, MBEN has
                     mushroomed into a Northeast Business Environmental Network.

              O     The Merrimack Project also showed how Total Quality Management
                     (TQM) techniques can be used by a state agency as a tool in creating a
                     pollution prevention program and in implementing pollution prevention
                     technical assistance to industry.
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       (The New Hampshire Department of Environmental Services used TQM
       while constructing the New Hampshire Pollution Prevention Program
       (NHPPP). Program commitments were evaluated against existing
       resources. The procedure involved an investment and disinvestment
       process using TQM. As a result, resources and job functions were shifted
       within certain programs in order to create the NHPPP.)

The report presents the following implications of the Merrimack Project:

O     Because the project has demonstrated that environmental compliance can
       be obtained in conjunction with traditional enforcement related activities
       as well as by using technical assistance independently of enforcement, the
       project has highlighted that technical assistance should never
       necessitate the suspension of enforcement, or disinvestment in
       enforcement.

O     The project has also verified that P2 technical assistance is an effective
       tool for encouraging and achieving environmental compliance.

O     The following is quoted from Region 1 (New England)'s report on the
       Merrimack Project:

       "The Merrimack Project experience has overcome the deep-seated
       mindset that EPA, as well as state environmental agencies, must serve
       solely as a regulatory agency, taking a "hands off approach to
       offering technical assistance....The Merrimack Project resolved many
       myths on whether or not a regulatory organization could successfully
       implement pollution prevention."

O     The Merrimack Project produced numerous examples of "how to
       methods" of integrating pollution prevention and technical assistance
       programs into enforcement related activities, while taking into
       consideration management's concerns.

       The following is quoted from Region 1 (New England)'s report:
       "The project has produced a network of valuable technical assistance
       resources that can assist management and staff. As a result, the
       project has increased the ability of each and every person at EPA
       Region 1 (New England) to access this information more readily than
       ever....The project also provides us in EPA Region 1 (New England)
       with additional insight on various techniques that we might consider
       when promoting or implementing pollution prevention."
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The report concludes by presenting next steps for EPA Region 1 (New England)
- hereinafter referred to as EPA - New England - to take in building upon the
Merrimack Project:

O      Support P2 technical assistance — both separate from and in conjunction
       with water quality evaluations, permit writing/negotiations, and
       compliance.

O      Strengthen the performance measures for compliance and enforcement
       activities to include not only the numbers of permits, inspections, and
       enforcement actions but also measures of environmental results.

O      Undertake three proposed EPA - New England FY95 P2 initiatives. (Each
       initiative is specified in the report on the Merrimack Project.)

O      Support the development of local discharge limits that are based on best
       available technology which recognizes and credits P2 technology.

O      Support and involve POTWs in P2 technical assistance by assisting them
       in negotiating implementation schedules with their respective industrial
       users.

O      Provide incentives to stimulate development and application of new
       technology to achieve P2 and more cost-effective measures to meet limits.

O      Support provisions in CWA reauthorization to incorporate more P2 in
       permitting. In the meantime, take advantage of every opportunity to
       integrate P2 into permitting, e.g., implementation measures, compliance
       schedules, outreach, and reporting.

O      Develop integrated data management systems to...make it possible to
       target P2 technical assistance to the most critical industrial facilities. (The
       Merrimack Project revealed that such a system was lacking and would be
       helpful if it existed.)

The report then describes the newly-formed New England Environmental
Assistance Team (NEEAT) and what it will be doing.

The report ends with the following sentence:

    "  In sum, the Merrimack Project has provided important experience
       with assistance tools, partnerships, and geographic focus that now
       forms EPA - New England's own assistance efforts.11
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12.    New England Demonstration Project: Building Partnerships for P2

( The Merrimack Project: Building Partnerships to Prevent Pollution in a Watershed (a summary
 report published by the Commonwealth of Massachusetts's Office of Technical Assistance) )

[See the introduction  under 10. on page 25.]

This Building Partnerships report is a summary report of the IP3's New England Demonstration
Project, i.e., the "Merrimack Project," from the Commonwealth of Massachusetts^ perspective.

       Value

       Federal and state policy makers can learn from the experiences and insights that
       Massachusetts gained from the IP3's "Merrimack Project."

       Major Findings and Conclusions

       The objectives of the Merrimack Project were met. Those objectives were:

          O  to promote pollution prevention as an ethic by working directly with businesses in
             the Merrimack watershed;

          O  to identify opportunities to incorporate pollution prevention into regulatory
             practices and policy, and to coordinate P2 efforts with regulatory agencies;

          O  to encourage industry, regulators, and others to view pollution prevention as a
             means of achieving both environmental protection in the watershed and economic
             health for local companies.

       Among the project's results:

          O  Pollution prevention outreach and education efforts, including workshops for
             businesses (several tailored for specific industries) and training sessions for
             POTW and regulatory staff, resulted in increased requests by industry for P2
             technical assistance.  Massachusetts's Office of Technical Assistance staff worked
             with more than 55 companies in the Merrimack watershed during the project.

          O  Ten Massachusetts companies together eliminated nearly 1.7 million pounds of
             toxic pollutants, and 18 companies saved $1.85 million by implementing P2
             strategies. Several other companies also reported reduced pollution and cost
             savings,  but did not have specific numbers. The total amount of pollution
             prevented and money saved is believed to be much greater than the numbers
             reported.
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  O  A group of regional businesses that began meeting informally through this project
      with government officials and environmental advocates to exchange information
      about P2 has incorporated as a nonprofit organization called the Northeast
      Business Environmental Network (NBEN). A nonpartisan network dedicated
      solely to helping its members improve their environmental performance in
      manufacturing operations, NBEN has been recognized as a model business-
      government partnership.

  O  Training and informational exchanges between Massachusetts's Office of
      Technical Assistance (OTA) and Massachusetts's Department of Environmental
      Protection (DEP) that began with this project have evolved into an ongoing
      exchange between the agencies,  including company referrals by DEP to OTA's
      technical assistance services.

  O  Information exchange between Massachusetts and New Hampshire environmental
      agencies resulted in the conduct  of joint public events, cooperation in the
      formation of NBEN, and a unified message promoting pollution prevention in the
      watershed.

In accord with the theme contained in its title, "Building Partnerships," this report by
Massachusetts describes in detail three aspects of the IPS's Merrimack Project:

         working with POTWs

         —   The  project conducted P2 training for POTW personnel.

         —   Working with POTWs, industry-specific workshops and conferences on
              P2 were organized.  Invitations were mailed out by POTWs to dischargers
              in their area.  Approximately 200 attendees learned about specific P2
              strategies and technologies, and heard businesses with P2 success stories
              tell how they saved money or improved quality while avoiding pollution.
              Target industries for the  workshops were selected by analyzing POTW
              permit lists and consulting with POTW operators. POTWs reported
              positive outcomes from their involvement in the workshops. (Those
              outcomes are presented in the report.) The Lowell, Greater Lawrence,
              Newburyport, and Haverhill POTWs, for example, have continued the
              practice of holding public events to educate their dischargers, and requests
              have come in from other POTWs in the state to conduct similar events.

         —   POTWs gained a better understanding of and appreciation for pollution
              prevention as a means of helping businesses remain in compliance with
              discharge limits, or eliminate the use of certain  chemicals altogether.

         -   The  Merrimack Project gave POTW officials a  chance to help dischargers,
              as opposed to simply enforcing against them.

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   ~   POTWs shared strategies with each other.  For example, the Newburyport
       POTW told other POTW officials how they have incorporated into some
       permits a requirement that dischargers report chemical purchases to the
       POTW; the Greater Lawrence POTW shared how it has added P2
       questions to its full inspection forms.

   ~   The Merrimack Project increased POTWs' interaction with each other,
       with industry, and with the state, leading to improved and effective
       communications and relations.

  working with businesses

   ~   The report addresses working in partnership with 58 companies during the
       Merrimack Project, including electronics manufacturers, machine shops,
       web coaters, metal platers/finishers, printers, printed circuit board
       manufacturers, spray paint contractors, the plastics industry, adhesive
       manufacturers, textiles, paper, furniture, leather products, wood stain,
       Pharmaceuticals, and other specialty products.

   ~   The report also describes the Merrimack Project's establishing the
       Merrimack Business Environmental Network (MBEN) — which has
       expanded to become the Northeast Business Environmental Network
       (NBEN) — and its growing influence.

- coordination with regulatory agencies and programs

   --   An objective of the Merrimack Project was to coordinate with regulatory
       programs, both to increase regulators' awareness and understanding of P2
       opportunities and to better define and enhance the relationship between
       regulation/enforcement and technical assistance. In addition, the project
       sought to identify opportunities and barriers to incorporating P2 in the
       work of regulatory agencies and to test new initiatives.

       MA OTA adopted the strategy of establishing training exchanges and
       referrals with the MA DEP (the state's environmental regulatory agency).
       At the same time, MA DEP made pollution prevention a top priority and
       has reorganized accordingly.

   —   As part of the Merrimack Project there was P2 training for EPA inspectors
       and managers, MA DEP inspectors and managers, POTW pretreatment
       coordinators, board of health agents, and audiences made up of regulatory
       officials of various agencies and authorities.

   --   The concept of P2  technical assistance initially raised several concerns
       among regulatory officials. These concerns included:

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       that resources would be diverted from enforcement or that
       enforcement would somehow be diminished;

       that the touting of P2 could seem to mean a denigration of
       pollution control;

       that if inspectors made suggestions concerning P2 activities,
       companies would interpret these suggestions as commands.

During the Merrimack Project, MA OTA addressed these concerns with
the following points:

       Technical assistance can be provided with a minimal devotion of
       resources, or with the incorporation of the function into existing
       programs, or with the use of new resources (e.g., based on fees).
       Assistance should not replace enforcement but should complement
       it, because strong enforcement is of paramount importance — it is
       the major reason why companies implement P2 or seek technical
       assistance.  Complementing enforcement with assistance improves
       the relationship between government and the regulated community.
       Assistance is the appropriate tool for interacting with those
       members of the regulated community who want to do the right
       thing and simply need a better understanding of the requirements
       and options.

       Although the hierarchy means prevention should be exercised first
       and foremost, it must be recognized that when it is not
       implemented, recycling, treatment, or other appropriate
       management of wastes already generated is still preferable to
       certain other alternatives.  It has been necessary to affirm on many
       occasions that pollution reduction is a desirable activity, even if it
       is not prevention.

       Inspectors could and should refer companies to a  technical
       assistance agency for specific help, while talking  about P2 in
       general to indicate the priority the agency places on the approach.
       Inspectors can also adopt the strategy of asking questions in lieu of
       making commands, because asking questions is a nondirective
       method of illuminating P2 opportunities and pointing a company in
       the right direction and denotes respect for the regulated company
       arid can enhance the relationship between the company and the
       regulator.  (In addition, dialogue concerning the process educates
       the inspector, which can improve regulatory practices.)
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         ~  The Merrimack Project also confirmed the importance of seeking to tailor
             enforcement strategies to encourage P2, through measures such as:
             waivers, extra time, penalty mitigation, and elimination of roadblocks to
             process changes. MA OTA staff frequently worked with companies
             facing short timeframes to address violations.  Conventional end-of-pipe
             control equipment is readily available. To supplant the control technology
             with a preventive technique may only be possible if the company has the
             time for investigation and trial.

             Coordination between MA  OTA and MA DEP has now evolved to mutual
             exchange. For example, DEP now sends copies of all Notices of
             Noncompliance to OTA, and included in these notices is language
             encouraging the recipient to contact OTA for help. Inspectors often
             recommend OTA's services to companies.

Among the report's stated conclusions are the following:

   The results of the Merrimack Project demonstrate that —

       O     industry and regulatory agencies are very receptive to education and
             information programs about P2, and can work  together effectively to
             educate others about specific P2 strategies and the possible benefits;

       O     businesses that implement P2 can reduce the amount of toxic byproducts
             reaching the environment and at the same time realize significant cost
             savings;

       O     many businesses are very concerned about environmental protection as
             well as the bottom line and are willing to share successful P2 strategies
             with other companies.

   The lasting results of the Merrimack Project include ~

       O     many companies in the Merrimack watershed adopting P2 strategies, and
             changing forever the way they approach the environmental issues relating
             to their operations;

       O     the establishment of the Northeast Business Environmental Network
             (NBEN), a model nonpartisan business-government network dedicated to
             promoting P2 as a means of achieving environmental protection and
             maintaining economic competitiveness, and providing increased sharing of
             information among businesses and between businesses and government
             and environmental organizations;
                                   39

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      O     an improved understanding of P2 opportunities by regional POTWs and
             MA DEP inspectors, and collaboration among POTWs, MA DEP, and MA
             OTA in promoting P2 as the preferred approach to industrial
             environmental problems;

      O     the identification of opportunities to incorporate P2 into environmental
             regulations and policy;

      O     increased understanding that environmental improvements need not be at
             the expense of economic progress;

      O     increased awareness by businesses in the Merrimack region of the
             importance of local natural resources; and

      O     increased awareness by governmental officials of the point of view of
             businesspeople who wish to be environmentally friendly.

The Appendices to the .report contain a published article on MBEN (later to become
NBEN)  and 15 "true tales" of technical assistance conducted during the Merrimack
Project.  The "True Tales of Technical Assistance" are presented to assist anyone wishing
to understand in detail how a P2 technical assistance program actually works.
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13.    Nebraska Demonstration Project

(Pollution Prevention at an Aging Midwestern Manufacturing Facility  (EPA-820-R-95-009))

[See the introduction under 10. on page 25.]

One of the IPS's four demonstration projects was in Nebraska. The goal of the Nebraska project
was to demonstrate the adoption of pollution prevention measures at a rural and aging metal
products manufacturing facility.

       Value

       Industry can learn from the thorough — and very detailed — P2 opportunity assessment
       and the P2 implementation experiences of this metal products manufacturing case study.

       Major Findings and Conclusions

       O     Waste disposal at this facility had resulted in potential problems, especially to
             surface and ground water resources in the area. The economic viability of the
             company depended on addressing the pollution problem and reducing pollution
             control expenses.

       O     In conducting the thorough and very detailed P2 opportunity assessment,
             emphasis became focused on those areas where the impact on reducing the total
             pollutant load would be the greatest. Those areas were the electroplating, hot-dip
             galvanizing, and the painting lines as well as  the tube mill production process.

       O     For each of those four areas, specific P2 process and/or materials changes were
             recommended and are described in detail in the project report.  Besides the
             technical details, the project report also presents the pollution load
             reductions, financial costs, and payback periods.

       O     One of the major considerations in making P2  recommendations to this company
             was that the facility was old and not very profitable. Therefore, recommendations
             for process and operational modifications resulting from the P2 opportunity
             assessment had to meet critical payback periods. The good news from this project
             is that the P2 recommendations that have been implemented thus far have
             provided quick payback and have truly revitalized the company!

       O     The company is very pleased with their adoption of P2. The P2 process and
             materials changes have not only increased company profitability but have
             significantly improved product quality as well! For example, the level of rust
             protection in the facility's products increased up to  1000%, which delighted the
             company because numerous claims had been made against the company in the
             past because of corrosion of some of its products.

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      O     The environment has also greatly benefited from the company's adoption of
             P2.

      O     The project also developed longer-term recommendations for the facility in
             addition to the shorter-term recommendations that have already been
             implemented.  Those longer-term recommendations are also described in the
             project report. The company is currently well on its way in implementing the
             longer-term recommendations. Implementing P2 and thereby improving
             facility performance and profitability will continue on into the future at this
             manufacturing site in Nebraska.

      O     Finally, while the primary goal of this project was to demonstrate the adoption of
             P2 at a rural, aging, not-very-profitable metal products manufacturing facility, a
             secondary goal of the project was to demonstrate how to involve a nearby
             university ~ in this case, the University of Nebraska at Lincoln - in a
             cooperative and collaborative approach to promoting P2 implementation.
             The approach involved industry, the university, and EPA.  (EPA (i.e., the IP3)
             provided "seed money" in the form of a small grant to the university, the
             university provided matching funds, and the industry agreed up-front to work
             closely with the university during the P2 opportunity assessment and fund the
             recommended P2 implementation.) The project demonstrated it to be an excellent
             approach.  It proved to be a very effective way to bring about P2
             implementation and each party gained something from the collaboration.

      O     Articles on this demonstration project have been published in Environmental
             Solutions, as well as in Water Science and Technology and the proceedings from
             several different conferences where this project has been presented.
14. and 15.   Nebraska Demonstration Project:  Technical Reports #1 and #2

( #1:   Pollution Prevention in the Commercial Sector: Waste Stream Assessment in the Metal
       Finishing Industry   (available from the University of Nebraska-Lincoln libraries)  )

(#2:   Waste Minimization Opportunities for the Electroplating Industry  (available as above)  )

Technical Report #1 is a lengthy, highly detailed, very technical report on the P2 opportunities
for the metal finishing industry — specifically the galvanizing, painting, and tubing fabrication
processes. Technical Report #2 is a lengthy, highly detailed, very technical report on the P2
opportunities specifically for the electroplating process.

       Value

       Those who need to know all the technical details and all the technical rationale behind the
       P2 measures for those four metal finishing processes can learn them hi these two reports.

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16.    Southern California Demonstration Project

( Pollution Prevention at Industrial Laundries: A Collaborative Approach in Southern California
 (EPA-820-R-95-012) )

[See the introduction under 10. on page 25.]

One of the IPS's four demonstration projects took place in Southern California. Its purpose was
to demonstrate a collaborative approach to promoting pollution prevention, i.e., how enhanced
communication and coordination among federal, state, and local regulatory agencies in a region
of a state can be conducted to promote P2 within a selected industrial sector.  The industrial
sector chosen for this demonstration was industrial laundries.

       Value

       Federal, state, and local policy makers and regulators can learn from this interagency,
       multi-media demonstration of enhanced communication and coordination among the
       regulators and with the regulated.  Industry can learn from the P2 opportunity
       assessments and P2 options developed in this demonstration.

       Major Findings and Conclusions

       O     The large number of federal, state, and local laws, regulations, agencies, policies,
             and enforcement practices regarding toxic pollutants is often overwhelming and
             sometimes conflicting, confusing, and frustrating to businesses.  To be most
             effective, P2 must be promoted through the unified efforts of all the regulators.

       O     All of the laws and regulations currently in place in California that create an
             incentive for industry to engage in P2 were collected, analyzed, and summarized.
             A report was produced, A Summary of the Regulatory Incentives for
             Pollution Prevention.

       O     All agencies (federal, state, and local) with requirements affecting multi-media P2
             in Southern California were formally invited to participate in this demonstration
             project.  Twenty-four different agencies attended and participated in the project
             meetings and formed the interagency multi-media team to demonstrate a
             collaborative approach to promoting P2 implementation at industrial laundries.

       O     The project produced a Report on Areas in Need of Coordination which
             identifies and  discusses specific air quality, water quality, solid/hazardous waste,
             and other regulatory programs that need coordination in order to have a unified
             approach to pollution prevention in Southern California.

       O     To industrial laundries, the area most in need of coordination is resolution of
             the  "shop towels as hazardous waste" issue.

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O      Detailed facility assessments were conducted at industrial laundries
       throughout Southern California (see 17. Southern California Demonstration
       Project: Technical Report below), and the findings and results of these
       assessments were presented at a big workshop held in June 1993.

O      The June 1993 workshop was developed by the interagency multi-media
       team as a blueprint for future workshops. The workshop took a multi-media
       approach and was conducted in partnership with the industrial laundries.
       Presenters at the workshop were  from regulating agencies and industrial laundries.

O      Discussions with industrial laundry operators and management during facility site
       visits and during the project meetings revealed several key points, including:

              Industrial laundries have  coped with the problem of non-compliance with
              local toxic organics and oil and grease limits by discontinuing the
              laundering of shop towels and shop uniforms at the facilities subject to
              stringent limits. Instead, the materials are taken to facilities not subject
              to stringent limits.

              The usual discharges to the environment from industrial laundries are
              washwater draining to sewers, solvents from fabrics evaporating to the air,
              filter cakes taken to landfills, and oil from water/oil separators taken to
              recyclers. The facility assessments confirmed that, while there are sources
              of pollutants internal to the laundry (e.g., detergent residues, truck
              cleaning, etc.), the bulk of pollutants found in laundries' discharges
              originate in the material received from customers. Toxic organic
              compounds and oil and grease were the two pollutants most causing the
              industrial laundries to be in non-compliance with environmental
              regulations.  The greatest contributor of those two pollutants were
              shop towels (and rags and uniforms) impregnated with solvents and oil.

              Industrial laundries are subject to conflicting, single-media regulations
              and inconsistent requirements which result in overall reluctance to take
              the "risk" of pollution prevention innovations.

 O      The project identified 16 specific pollutants of concern for industrial laundries
        and probable sources of those pollutants.

 O      The project showed that there are P2 opportunities available for both
        laundries and their customers. For both, the establishment of and adherence to
        a set of best management practices (BMPs), followed by continuous improvement
        in searching for ways to minimize the generation of pollutants, is the key.  The
        project produced a listing of BMPs for industrial laundries and their customers.
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O     The Multi-Agency Work Group, recognizing that one of the biggest problems for
       laundries and the area of most concern for regulatory agencies is dealing with
       shop towels, suggested that P2 options for laundries that process shop towels
       could include:

             education of their customers on P2 opportunities to prevent shop towel
             contamination;

             use of BMPs at the customer's site prior to transportation to minimize the
             amount of solvent in the material accepted by the laundry for washing; and

             use of BMPs for the safe handling of solvent-laden shop towels, which
             might include:

                           requirement of no free liquids
                           use of the paint filter test (used by some states)
                           use of a wring test (hard to standardize)
                           collection containers with mesh bag (to allow settling)
                           weighing towels and rejecting those above certain weight
                           centrifuges mounted on trucks

             (A more complete and detailed list of BMPs for shop towels, both for the
             laundries and for the customer, was produced by the project — along with
             two pages of points on why BMPs are important and how they are
             beneficial for the laundries. These materials, developed for the
             workshops, were disseminated to the laundries and their customers.)

O     The interagency multi-media team discussed how two states (Minnesota and
       Washington) have resolved the "shop towels as hazardous waste" regulatory issue.

O     Besides the importance to Southern California industrial laundries  of resolving the
       "shop towels as hazardous waste" issue, there also needs to be ongoing
       interaction between the local POTWs and the laundries. Laundries want to
       know what causes problems for POTWs (e.g., What are their contaminants of
       concern? What's hard for them to treat?)

O     There needs to be a dialogue and a cooperative effort between POTWs and
       laundries to help identify whether or how the laundries' customers  are contributing
       to POTW problems and what can be done about it. Laundries and POTWs need
       to focus on ways of transferring information. It is important also that
       laundries and regulatory agencies work cooperatively together in providing
       to customers training and periodic retraining in P2 and the use of BMPs.
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O      The inter agency multi-media team, in cooperation with management and
       personnel representatives of industrial laundries, developed a strategy which
       an industrial laundry could adopt for the P2 program:

              (1)    Make everyone a part of the same P2 team - internal team
                    members would include laundry operating personnel, staff and
                    management, distributors and route drivers; external team
                    members would be the laundry's customers.

              (2)    Develop best management practices (BMPs) for internal and
                    external handling of laundry ~ at the laundry and at the customer's
                    shop. (The project produced a listing of possible BMPs for
                    laundries and their customers.)

              (3)    Train and periodically retrain internal staff and customers.

              (4)    Use route representatives and salesmen to disseminate BMPs and
                    ensure that these practices are consistently applied in the
                    customer's shop at pick-up, transfer, and delivery. (The project
                    produced a written strategy for this dissemination of BMPs to
                    customers.)

              (The workshop held in June 1993 put forth ideas and materials industrial
              laundries and regulatory agencies can use to implement this strategy.)
The project concluded the following:

O     Any effective P2 program for industrial laundries needs to extend into the
       customer's shop. The customer is an integral part of the industrial laundries'
       environmental compliance program. (This reality was a major reason industrial
       laundries were selected as the industry for this demonstration — because involving
       the one industry (industrial laundries) in a P2 emphasis naturally leads to
       involving many other industries as well.)

O     The transfer of solvents, oils, and other pollutants to towels, rags, and
       uniforms by the customer should be considered emissions to the environment
       and should be accounted for in the customer's overall emissions.

O     A P2 program for customers needs to be applied universally and  consistently
       to retain competitiveness of individual laundering facilities.

O     Industrial laundries' control of emissions from customers to the laundering
       facility needs to be done in partnership with the customer - and with the
       support of regulators.

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O      The challenge for regulators and industry is to find a mechanism, both
       regulatory and administrative, to extend P2 beyond the industrial laundry facility
       into the customer's shop and incorporate the customer (i.e., the generator of the
       pollutants) into the P2 program.  The basis for developing such a mechanism
       should be a partnership among laundry, customer, and regulator, supported by a
       mix of regulatory mandates and incentives.

O      The collaboration and cooperation that was instituted by this demonstration
       project must continue into the future. Especially with U.S. EPA continuing to
       work on developing effluent guidelines for industrial laundries, it is important to
       maintain the partnerships established in this project. For example,  it is important
       to:

             continue with the interagency multi-media team meetings with industrial
             laundries and local agencies to (1) assess progress in implementing BMPs;
             (2) serve as a sounding board for the U.S. EPA's effluent guidelines work
             group; (3) work on other existing and emerging issues; and (4) conduct
             any issue-specific meetings of value to participants.

             have local agencies, with the laundries, jointly coordinate P2 outreach
             (e.g., a joint letter from different regulatory agencies emphasizing BMPs)
             to the laundries' customers.

             continue — as a team — to publicize and disseminate the findings and
             materials from the project.
This demonstration project brought together in Southern California all the different
regulatory agencies and industry for the first time — as a team.  It provided a
valuable forum to inform everyone of everyone's concerns and put everyone on the
same "wave length."  It instituted a new ongoing dialogue among all the regulatory
players.  It can serve as a model for how this collaborative, team approach can be
done in other regions.

In summary, the overall message of the IP3's "collaborative approach in Southern
California" is  that the best way to get good things done is through partnerships.  In
order to be most effective in promoting the implementation of pollution prevention,
we need a sense of partnership among the various regulators, among the regulators
and the regulated, between POTWs and their users, and between industrial
laundries and  their customers.  This project has demonstrated that these parties  can
work successfully together in a spirit of collaboration and cooperation. It is
important that this spirit that has been established in Southern California continue
there and be fostered in other places as well.
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17.    Southern California Demonstration Project: Technical Report

( Pollution Prevention at Industrial Laundries: Assessment Observations and Waste Reduction
 Options  (EPA-820-R-95-010)  )

This technical report on P2 opportunities and waste reduction options is based on the detailed
industrial  laundry facility assessments conducted as part of the Southern California
demonstration project.

       Value

       Laundry facility operators and government regulators can learn about P2 opportunities
       and waste reduction options; and corporate management of industrial laundries can learn
       that - through a strong commitment to an ongoing P2 program involving improved
       customer partnerships ~ their plants can achieve significant waste reduction.
       (The Institute of Industrial Laundries in its publications has disseminated information
       from this report to its members.)
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18.    Pacific Northwest Demonstration Project

(Pollution Prevention Assessment and Implementation at a Pulp and Paper Mill in the Pacific
 Northwest:  Summary Report   (EPA-820-R-95-011)  )

[See the introduction under 10. on page 25.]

One of the IPS's four demonstration projects was in the Pacific Northwest. Its purpose was to (1)
demonstrate pollution prevention opportunity assessment and implementation at a specific pulp
and paper mill in Tacoma, Washington; (2) develop a model pollution prevention plan for use by
other similar mills; and (3) provide a bibliography of publications related to pollution prevention
for the pulp and paper industry.  This demonstration project also showed how P2 can be
incorporated in permit writing and the enforcement settlement process.

       Value

       Industry and government regulators can leam about P2 opportunities for pulp and paper
       mills and can learn from  the P2 implementation experience of this Tacoma mill.

       Major Findings and Conclusions

       The IP3 in cooperation with the Simpson Tacoma Kraft Company and the Washington
       State Department of Ecology conducted in early 1992 a study of the opportunities for
       pollution prevention at the company's Tacoma mill.

       O     The assessment identified and evaluated nearly fifty feasible P2 alternatives,
             which are listed in Tables 4 and 5 of the assessment report (see 19. Pacific
             Northwest Demonstration Project:  Simpson Tacoma P2 Plan below). The tables
             include a description, estimated pollution reduction benefits, approximate cost,
             and suggested priority of each of the P2 alternatives.  Cost estimates for each
             alternative range from several thousand dollars to several million dollars.

       O     Recommendations were made to Simpson Tacoma management to develop
             an ongoing P2 program and implement near-term and long-term process
             modifications to  attain P2 benefits.

                    Seventeen near-term options, for implementation within 1 to 5 years,
                    were recommended. (See 19. Pacific Northwest Demonstration Project:
                    Simpson Tacoma P2 Plan below.)

                    Nine long-term options, for implementation within 5 to 10 years, were
                   also recommended. (See 19. Pacific Northwest Demonstration Project:
                    Simpson Tacoma P2 Plan below.)
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O      To date, Simpson Tacoma has already implemented many P2 measures and
       is in the active process of implementing many more. These include 11 of the
       near-term options and 4 of the long-term options. The investment cost for all
       the measures implemented to date totals over $100 million.

O      Some of the P2 measures already being implemented include:

             Woodyard (Chip Handling)

                    chip area fencing
                    modify chip unloading

             Pulping and Chemical Recovery

                    reuse condensate on washers
                    black liquor spill recovery
                    No.4 brownstock washer
                    upgrade recausticizing area
                    non-condensible gas system expansion
                    expansion of mill capacity with addition of recycle fiber

             Bleaching

                    new bleach plant
                    chlorine dioxide plant chiller
                    hydrogen peroxide extraction

             Pulp Dryers and Paper Machines

                    partial steam condensate recovery
                    reuse No. 14 paper machine white water at pulp mill
                    replace wet strength resin containing formaldehyde

             General Mill Operations

                    No.7 power boiler
                    stormwater collection
                    replacement of PCB-containing transformers
                    asbestos abatement program
                    bulk chemical purchases to reduce drum management
                    eliminated use of chlorinated solvents
                    minimization of miscellaneous hazardous wastes
                    improved water conservation and reuse
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O      Most of the major expenditures were for process or utility system upgrades that
       provide significant P2 benefits as well as product quality and resource
       utilization benefits.  For example:

             Installation of the No.4 brownstock washer and associated screening and
             deknotting systems and the new bleach plant resulted in substantial
             reduction in bleach plant chemical consumption and the amounts of
             chlorinated compounds generated, while yielding bleached pulp of higher
             quality suitable for a wider range of markets than would otherwise have
             been possible.

             Installation of the No.7 power boiler resulted in significant atmospheric
             emission reductions and improved resource utilization through enhanced
             combustion efficiency.

O      The generation of chloroform at Simpson Tacoma has been significantly
       reduced with the operation of the new bleach plant and elimination of the use of
       sodium hypochlorite  as a bleaching agent. The results demonstrate that
       formation of chloroform can nearly be eliminated if elemental chlorine is
       replaced with chlorine dioxide for pulp bleaching in the first bleaching stage.
       Current operating practice at Simpson Tacoma is to operate at an average 85%
       chlorine dioxide substitution rate for most grades and at 100% substitution for
       selected products. Simpson Tacoma's P2 effort has reduced dioxin to non-
       detect levels and AOX and chloroform by 80% and 90% respectively.

O      In many cases, Simpson Tacoma has also realized cost savings from the P2
       efforts.  For example:

             Water consumption savings of 2.9 mgd from reuse of evaporator
             condensates result in an annual savings of about $300,000. The
             investment cost for that measure was only $100,000.

O      Simpson Tacoma's P2 accomplishments to date reflect what can be achieved at
       basic industries involved in processing large amounts of materials. Major P2
       benefits will accrue as production processes and utility operations are changed.

O      Besides the several P2 measures already so successfully implemented,
       Simpson Tacoma will be implementing additional measures over the coming
       years. It is clear that Simpson Tacoma's P2 efforts will continue to be an
       ongoing program.
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O      Simpson Tacoma's P2 implementation plan (see 19. Pacific Northwest
       Demonstration Project: Simpson Tacoma P2 Plan below), containing a
       commitment to make both near-term and long-term process modifications, will be
       used by Simpson Tacoma and the Washington State Department of Ecology
       as a partial fulfillment of the State's requirement for a pollution prevention
       plan under the State's hazardous waste law. U.S. EPA will use the plan as an
       example of a successful P2 plan for the pulp and paper industry.

O      This Pacific Northwest Demonstration Project also developed a model P2
       plan for pulp and paper mills, for use at other mills. (See 20. Pacific Northwest
       Demonstration Project: Model P2 Plan (Pulp and Paper MilH below.)

O      This model P2 plan has proved useful throughout the Pacific Northwest, not only
       to pulp and paper mills but also to permit writers.

O      The P2 ideas and options in the model P2 plan have also been useful to
       enforcement personnel in enforcement settlements.

O     The Pacific Northwest Demonstration Project also produced an  extensive,
       annotated bibliography on pollution prevention for the kraft pulp and paper
       industry.  (See 21. Pacific Northwest Demonstration Project: Bibliography
       below.)
 As a result of this IPS Pacific Northwest Demonstration Project, Simpson Tacoma
 received very favorable local and national recognition. This recognition resulted in
 benefits not originally expected by the company:

 First, the company gained a fresh perspective on U.S. EPA and now sees the agency
 as more than just a regulator. Simpson Tacoma now has increased confidence in
 dealing with the agency on technical or process related issues.  Simpson Tacoma also
 believes that its experience through the IPS demonstration project has shown to other
 companies as well that EPA will work with companies in a cooperative manner.

 Second, the recognition has brought other state and federal voluntary programs to
 Simpson Tacoma that have maintained the momentum of the original IPS effort.
 Subsequent to the IP3 demonstration at Simpson Tacoma and the company's
 implementation of the project's P2 recommendations, a State of Washington project on
 measuring pollution prevention has been conducted at the facility. In addition, Simpson
 Tacoma submitted an application to U.S. EPA's Environmental Leadership Program
 and was one of only 10 private companies selected nationwide!  In light of the IP3's
 objective to spread the P2 ethic, it is perhaps not without significance that, under the
 Environmental Leadership Program, one of Simpson Tacoma's projects will be to
 conduct a supplier mentoring program whereby Simpson Tacoma will now work to help
 enhance the environmental performance of its suppliers.

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19.    Pacific Northwest Demonstration Project; Simpson Tacoma P2 Plan

(Pollution Prevention Opportunity Assessment and Implementation Plan (EPA 910/9-92-027))

This is a P2 opportunity assessment and implementation plan for the Simpson Tacoma Kraft
Company pulp and paper mill in Tacoma, Washington. It was done by the IP3 in cooperation
with Simpson Tacoma and the Washington State Department of Ecology. It describes the mill
and its operations, the P2 opportunity assessment and its results, an evaluation of the P2 options,
and the recommended P2 implementation plan.

       Value

       Industry and government regulators can learn about P2 possibilities for a kraft pulp and
       paper mill, as well as how to conduct a P2 opportunity assessment and develop a P2
       implementation plan.

       Major Findings and Conclusions

       O     The assessment identified and evaluated nearly fifty feasible P2 alternatives,
             which are listed in Tables 4 and 5 of the document. The tables include a
             description, estimated pollution reduction benefits, approximate cost, and
             suggested priority of each of the P2 alternatives.  Cost estimates for each
             alternative range from several thousand dollars to several million dollars.

       O     The recommended P2 implementation plan included 17 near-term and 9
             long-term P2 suggestions.

             Near-term P2 recommendations (for implementation within 1 to 5 years):

                (an asterisk (*) denotes the highest priority recommendations)

                    fugitive dust control related to chip piles *
                    stormwater control related to chip piles
                    indirect heat exchangers on batch digesters *
                    utilization of boiler ashes and slaker grits *
                    exhaust smelt tank vents to No.7 power boiler
                    expansion of non-condensible gas system *
                    black liquor spill prevention and recovery *
                    improved water conservation and reuse for the paper machines and pulp
                    dryers *
                    improved steam condensate recovery for the paper machines and pulp
                    dryers
                    ammonia discharge control
                    save-alls on pulp dryers
                    replacement of PCB-containing transformers *

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             asbestos removal *
             increased bulk purchases to eliminate drums *
             minimization of miscellaneous hazardous wastes *
             improved steam condensate recovery throughout mill
             improved water conservation/reuse throughout mill *

       Long-term P2 recommendations (for implementation within 5 to 10 years):

             expand mill capacity with addition of secondary fiber
             replace existing batch digester kraft capacity with addition of secondary
             fiber
             replace No.2 and No.3 brownstock washers
             upgrade or replace No.3 recovery boiler
             install new MCC (modified continuous cooking) digester for bleached
             stock
             expand bleach plant capacity with oxygen delignification
             operate bleach plant at sustained 100% chlorine dioxide substitution
             install chip thickness screens
             steam strip foul condensates or incineration in power boiler.

O      The P2 implementation plan also points out and discusses the importance of
       and how to establish:

             management commitment to P2

             having a corporate framework for P2 (e.g., a P2 Committee)

             incorporation of P2 within the company's planning processes (capital
             appropriation and budgeting) as well as operating plans

             an environmental auditing program

             a tracking system for P2 successes

             P2 awareness among company employees.

O      Appendices to the document include:

             an outline for environmental and pollution prevention planning for a
             company

             an extensive glossary of pulp and paper industry terms and abbreviations

             a short technical description of the Simpson Tacoma mill's chlorine
             dioxide substitution results.

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20.   Pacific Northwest Demonstration Project: Model P2 Plan (Pulp and Paper Mill)

( Model Pollution Prevention Plan for the Kraft Segment of the Pulp and Paper Industry
 (EPA 910/9-92-030)  )

This is a model P2 plan for the kraft segment of the pulp and paper industry. It was developed
after the thorough P2 assessment and P2 implementation plan were done for the Simpson
Tacoma Kraft Company.  Its purpose is to provide a model P2 implementation plan that can be
used for other kraft pulp and paper mills.

      Value

      Industry and government regulators can use this model P2 plan to establish P2 at kraft
      mills throughout the Pacific Northwest and elsewhere.

      Major Findings and Conclusions

      O     The model P2 plan contains P2 options in each of the following process areas:

                   woodyard operations
                   pulping and chemical recovery
                   pulp bleaching
                   pulp drying and papermaking
                   wastewater treatment

      O     For each P2 option, there are a description of the P2 measure, its cost, its
             applicability, its benefits, and references for additional information about it.

      O     This model P2 plan has proved useful throughout the Pacific Northwest, not only
             to pulp and paper mills but also to permit writers.

      O     The P2 ideas and options in the model P2 plan have also been useful to
             enforcement personnel in enforcement settlements.

      O     This model P2 plan also presents an organizational and management
             framework for establishing a P2 program at a mill, describing the importance
             of:

                  management commitment
                  the establishment of a P2 team
                -  tracking the  performance of P2 measures after implementation.
                                         55

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21.    Pacific Northwest Demonstration Project: Bibliography

f Pollution Prevention for the Kraft Pulp and Paper Industry: Bibliography (EPA 910/9-92-031))

This is an annotated bibliography of publications related to pollution prevention in the kraft
segment of the pulp and paper industry.

       Value

       Industry (and any other interested parties) is provided with a handy and extensive
       reference guide to information about pollution prevention in the pulp and paper industry.

       Major Findings and Conclusions

       The bibliography references much information about P2 for the pulp and paper industry.

       The document is organized by process area as follows:

                     Chip Preparation
                     Chemical Pulping
                     Pulp Washing
                     Bleaching
                     Chemical Recovery
                     Recausticizing
                     Power Generation
                     Wastewater Treatment
                     Papermaking
                     General Plant

        The document contains 269 citations. Each citation contains: title, author,
        reference, and a brief synopsis.
                                           56

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22.    Consumer Education Handbook ,

(Influencing Consumer Choice and Assessing the Effectiveness of Risk Communication )

This handbook provides analysis and recommendations on how and when to communicate with
the public to influence consumer choices.  The underlying concept is that influencing consumer
choices (i.e., market demand) away from products that are a significant cause of pollution either
in their manufacture or in their disposal can be a very effective way to influence industry to adopt
pollution prevention.

It may not now be the role of U.S. EPA to influence consumers. But that could change.  This
handbook was developed by the IP3 with the conviction that, if EPA ever does assume a
consumer education role, it is vitally important that EPA do it cautiously and be able to do it
without making mistakes. The very thorough and thoughtful analyses behind this handbook lay
that sure foundation.

       Value

       U.S. EPA and other environmental agencies and interest groups can learn how and when
       to communicate with the public, so that it is done prudently and effectively.

       Major Findings and Conclusions

       Based on extensive background research and literature review, as well as the development
       and testing of consumer behavior models, the handbook presents the following three
       major results:

       O     There is an integrated framework available for examining the relationships
             between consumer choices, product risks, and risk communication.

             The project developed a detailed framework for evaluating the potential impact of
             consumer-targeted communication suitable for use in the context of EPA
             environmental policy. The method is based on a general model of consumer
             choice that has been validated in applications to a diverse range of consumer
             products and services.

       O     There is a tool for evaluating candidate products as potential subjects of a
             consumer education program.

             The project developed a "Product Screener." The Product Screener is to be used
             to evaluate the likely success of a consumer-targeted communication campaign
             for a specific product (or product category) and its associated environmental risk.
             The role of the Product Screener is to reject poor candidates. (The handbook
             illustrates the application of the Product Screener to three very different consumer
             products: lawn pesticides, dry cleaning, and paint strippers.)

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      O     There is a seven-step process for prudently developing a consumer-targeted
             communication strategy.

             The handbook describes, and illustrates by example, the various steps to direct the
             detailed design, testing, revision, and execution of a communication campaign for
             the targeted product area.

      The handbook is filled with detailed analyses, information, examples, and
      worksheets to aid and guide the user.
23.    IP3 Focus Group Recommendations:  P2 Information Sharing

The 23-member IP3 Focus Group (comprised of representatives from industry, labor,
environmental groups, academia, and all levels of government (federal, state, and local))
provided recommendations on the best ways to disseminate P2 information.

       Value

       Anyone interested in disseminating P2 information can learn what the stakeholders
       themselves recommend.

       Major Findings and Conclusions

       To disseminate P2 information most effectively, the IP3 Focus Group recommended
       doing so through:

       O    training of permit writers
       O    meetings with targeted audiences (not just sending them material)
       O    standardized dissemination systems (rather than informal ad hoc ones)
       O    university-based assistance programs
       O    non-regulatory agency assistance programs
       O    trade associations and other professional associations
       O    professional environmental auditing organizations
       O    the television medium
       O    the video cassette medium
       O    business publications (e.g., Business Week)
       O    state industry councils
       O    Chambers of Commerce

       Whatever method  is used, unless the audience is known to be technically oriented, be sure
       to translate the P2  information into "management's  language."

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Questions about the IPS or requests for any of the IPS documents can be addressed to:

                          Jim Lund
                          Director, IPS
                          U.S. EPA
                          401M Street, S.W.
                          Washington, DC 20460

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